Effective 20 August 2026
1.1 This policy explains how Dotmovs OÜ collects, uses, shares and protects personal data, and what rights individuals have in relation to that data.
1.2 It covers the dotmoovs mobile application, MOOV Studio, and the DeepSight movement analysis technology which powers both.
1.3 Where a professional using MOOV Studio uploads video of their own client or patient, that professional decides why and how the data is processed and we act on their instructions. In that situation the professional is the controller and we are the processor, and the professional's own privacy notice applies to the individual concerned. This policy describes the processing for which we are responsible.
1.4 Our contact details, and those of our data protection officer where appointed, are at clause 16.
1.5 Which parts of this policy apply to you depends on how you use our products. If you use the dotmoovs App with your own account, all of it applies to you and we are responsible for your data. If you are a professional using MOOV Studio, clauses 2, 6, 8, 9, 10, 11, 12 and 16 apply to your own account and business data; the data of your clients is governed instead by the Data Processing Agreement between us. If a professional you work with uses our technology to analyse video of you, that professional decides how your data is used, and you should ask them for their privacy notice.
3.1 Movement Data is central to the Service and we describe it separately because it is more sensitive than most of the data we hold.
3.2 When you record or upload video, our technology maps your body in detail and produces a representation of your position and movement. That representation is far more detailed than a simple set of joint positions.
3.3 We treat Movement Data as biometric data and therefore as a special category of personal data under Article 9 of the General Data Protection Regulation. We do this because a detailed representation of how a particular person moves may be capable of identifying that person. We take this position deliberately, and it means we ask for your explicit consent before processing it.
3.4 Video is uploaded to our servers, analysed, and retained for the period set out at clause 9. It is not made public and is not shared with other users.
3.5 You may withdraw consent to the processing of Movement Data at any time. If you do, movement analysis will no longer be available to you, because it cannot function without that processing. Other parts of the Service remain available.
4.1 We would like to use Movement Data to train and improve the models behind DeepSight. Better and more varied real-world data makes the analysis more accurate for everyone who uses it.
4.2 We only do this if you separately and expressly agree. It is optional, it is switched off unless you turn it on, and the Service works in exactly the same way if you decline.
4.3 You can turn this permission on or off at any time in Settings. Turning it off is as easy as turning it on.
4.4 If you turn it off, we will remove your data from our training set within 30 days and will not include it in any future training. We will not be able to remove your data from models that have already been trained, because that is not technically possible. We tell you this at the point at which we ask for your permission.
4.5 We may also anonymise data so that it can no longer be linked to you. Once data is anonymised it is no longer personal data and this policy no longer applies to it. We describe this at clause 5.
4.6 This clause applies only to individuals who hold their own account with us. Where a professional uses MOOV Studio to analyse video of their client or patient, we do not use that data to train or improve our models. We only use data for training where the person concerned has given us their permission directly.
5.1 We anonymise personal data where we can, so that we can understand how the Service performs and improve it without holding information that identifies anyone.
5.2 Anonymisation is irreversible. We do not attempt to re-identify anonymised data and we require anyone we share it with to give the same undertaking.
5.3 We may retain and use anonymised and aggregated data without a fixed time limit, including for research, for improving and developing the Service, and for the development of movement analysis models.
5.4 We may publish or share aggregated statistics which do not identify any individual.
6.1 We set out below each purpose for which we process personal data and the legal basis on which we rely.
Data: account details, profile information, physical and activity information, usage data, device data. Basis: performance of our contract with you.
Data: video, Movement Data. Basis: your explicit consent under Article 9(2)(a), together with performance of our contract.
Data: Movement Data and video. Basis: your separate explicit consent under Article 9(2)(a). Optional; see clause 4.
Data: usage data, device data, diagnostic data, anonymised data. Basis: our legitimate interest in understanding how the Service is used and making it work better, balanced against your interests.
Data: as described at clause 5. Basis: our legitimate interest in being able to analyse and develop the Service without holding identifiable data.
Data: account details. Basis: performance of our contract and compliance with a legal obligation.
Data: account details, communications, usage and device data. Basis: our legitimate interest in supporting our users, and performance of our contract.
Data: account details, contact details. Basis: performance of our contract and compliance with legal obligations.
Data: contact details, usage data. Basis: your consent, which you may withdraw at any time.
Data: transaction records, device data, usage data. Basis: performance of our contract, compliance with legal obligations, and our legitimate interest in protecting the Service.
Data: as necessary. Basis: compliance with a legal obligation, and our legitimate interest in establishing, exercising or defending legal claims.
7.1 We do not use Movement Data, video or health-related information for advertising.
7.2 We do not sell personal data that identifies you.
7.3 We do not make decisions producing legal or similarly significant effects about you by automated means alone.
7.4 We do not share your video with other users.
8.1 We share personal data with service providers who process it on our behalf and on our instructions, under written contracts. These currently include providers of:
A current list of our processors, including their identity and location, is available at https://dotmoovs.com/processors and is updated when it changes.
8.2 Where you use the dotmoovs App at the invitation of a professional, we share your results with that professional to the extent you have agreed. You can end that sharing at any time in Settings, and we will give effect to that without reference to the professional.
8.3 We may share personal data where required by law, by a court, or by a competent authority, and where necessary to protect the rights, safety or property of any person.
8.4 If we are involved in a merger, acquisition, financing or sale of assets, personal data may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a different privacy policy.
9.1 We keep personal data for no longer than is necessary. Our retention periods are:
9.2 Where you close your account we delete or anonymise your data in accordance with these periods. We retain records where we are required to do so by law or where necessary for the establishment, exercise or defence of legal claims.
9.3 Deletion is carried out by automated process and is logged.
10.1 Some of our service providers are located outside the European Economic Area.
10.2 Where personal data is transferred outside the European Economic Area, and the destination is not covered by an adequacy decision of the European Commission, we put in place appropriate safeguards, in most cases the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c), together with any additional measures required following a transfer impact assessment.
10.3 A copy of the safeguards in place may be requested using the contact details at clause 16.
11.1 We take appropriate technical and organisational measures to protect personal data, including:
11.2 No system is completely secure. If a personal data breach occurs which is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, you.
12.1 If you are in the European Economic Area you have the right to:
12.2 You can exercise most of these rights directly in Settings. Otherwise contact us using the details at clause 16.
12.3 We respond within one month. If a request is complex we may extend that period by up to two further months and will tell you if we do.
12.4 We may ask you to verify your identity before acting on a request, in order to protect your data and the data of others.
12.5 Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
13.1 The Service is not intended for and is not directed at anyone under the age of 18. We do not knowingly collect personal data from anyone under 18.
13.2 Professionals using MOOV Studio are contractually prohibited from uploading video of any person under the age of 18.
13.3 If you believe that we hold personal data relating to a person under 18, contact us using the details at clause 16 and we will delete it.
14.1 Our website uses cookies and similar technologies. Strictly necessary cookies are required for the site to function and cannot be declined. Other categories are used only with your consent, which you may give or withdraw through the cookie banner.
14.2 The mobile application uses software development kits provided by third parties for analytics, crash reporting and attribution. Where consent is required, we ask for it and the Service remains usable if you decline.
14.3 Further detail, including the categories, purposes and durations, is set out in our Cookie Notice at https://dotmoovs.com/cookies.
15.1 We may update this policy. The date of the current version appears at the top.
15.2 Where a change is material, or introduces a purpose that you would not reasonably expect, we will notify you in advance and, where the change requires it, ask for your consent rather than rely on notice.
15.3 Previous versions of this policy remain available at https://dotmoovs.com/privacy-archive.
16.1 Dotmovs OÜ, Harju maakond, Tallinn, Kristiine linnaosa, Kotkapoja, 10615, Estonia. Email support@dotmoovs.com.
16.2 Data protection officer: support@dotmoovs.com.
16.3 Not applicable. The Company is established in the European Union and therefore is not required to appoint a representative under Article 27 of the General Data Protection Regulation.
16.4 You have the right to lodge a complaint with the supervisory authority in the country where you live, where you work, or where you consider an infringement has taken place. The competent authority for us is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).